PPN 006 Explained: Carbon Plans for UK Contractors

PPN 006 requires a board signed Carbon Reduction Plan for UK public contracts over £5m per year. Here is exactly what contractors need to produce and when.

Why this matters now

Since February 2025, PPN 006 has become a hard gate in UK public procurement.

At the same time, NHS Evergreen Level 1 set 6 April 2026 as the deadline for suppliers to meet Level 1 requirements, which are built directly on PPN 006 compliance.

Many contractors already have a Carbon Reduction Plan. The issue is that plans created in 2023 often do not meet current expectations.

Common gaps now being flagged in tenders include:
• Missing Scope 3 categories
• No clear board approval evidence
• Plans not published on a public website
• Outdated or unclear baseline years

The consequence is simple.
If your Carbon Reduction Plan is not compliant, your bid is non compliant before it is even evaluated.

What PPN 006 actually requires

At its core, PPN 006 requires a supplier to produce and publish a Carbon Reduction Plan (CRP) with four non negotiable elements.

1. Scope 1 and Scope 2 emissions baseline

You must report your direct emissions and purchased electricity emissions using a defined baseline year.

This baseline must be:
• Clearly stated
• Consistent year on year
• Supported by actual data sources

2. Defined Scope 3 subset

You are not required to report all Scope 3 categories, but you must include a relevant subset.

For contractors, this typically includes:
• Purchased goods and services
• Fuel and energy related activities
• Waste generated in operations
• Business travel

This aligns with guidance from the Greenhouse Gas Protocol.

3. Net zero commitment by 2050

You must publicly commit to achieving net zero emissions by 2050 at the latest.

This is not optional. It is a core eligibility requirement.

4. Board sign off and public publication

The CRP must:
• Be approved at board or director level
• Include a named signatory
• Be published on your organisation’s public website

This is one of the most commonly failed requirements.

The £5m threshold explained

PPN 006 applies to contracts where the estimated value exceeds £5 million per year.

Two points are often misunderstood:

• The threshold applies per contract per year, not total company turnover
• It applies at the lot or framework level, depending on how the procurement is structured

This means a contractor with £20m annual turnover can still be caught by PPN 006 if bidding for a qualifying contract or framework lot.

In practice, many public sector frameworks now include this requirement by default.

Common mistakes contractors make

Across bids reviewed in 2025 and early 2026, several recurring issues appear.

Missing or incomplete Scope 3

Many CRPs include Scope 1 and 2 but either:
• Exclude Scope 3 entirely
• Include it without explanation
• Fail to define which categories are covered

No evidence of board approval

A statement alone is not enough. Procurement teams expect:
• Named director or board member
• Clear approval wording
• Ideally a dated sign off

CRP not publicly accessible

Uploading a CRP internally or behind a login does not meet the requirement.
It must be accessible via a public webpage.

Outdated baseline year

Some plans still reference baseline years without:
• Updated emissions data
• Annual progress reporting

This reduces credibility and may trigger clarification questions.

How NHS Evergreen Level 1 raises the bar further

The NHS Evergreen Level 1 effectively builds on PPN 006 and tightens expectations.

From 6 April 2026, suppliers must demonstrate:
• A PPN 006 compliant Carbon Reduction Plan
• Scope 1 and Scope 2 emissions reporting
• Relevant Scope 3 categories
• A net zero commitment

The key difference is verification and consistency.

Evergreen Level 1 is not just about having a document.
It is about demonstrating that your carbon reporting is:
• Structured
• Repeatable
• Embedded into your organisation

From compliance burden to competitive advantage

While PPN 006 may initially feel like an administrative requirement, it is quickly becoming a competitive differentiator.

Contractors who can demonstrate:
• Clear emissions data
• Structured reporting
• Credible reduction pathways

are increasingly favoured in procurement scoring.

This is particularly true in sectors such as healthcare, infrastructure, and local authority frameworks.

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